Implementing ISO 27001 Annex A 5.1 is the strategic process of establishing a comprehensive Information Security Policy framework. This control requires organizations to define, publish, and maintain topic-specific policies that mandate management approval and standardized document control. Successful implementation ensures clear organizational direction and demonstrates leadership commitment to information security.
ISO 27001 Annex A 5.1 Policies for Information Security Implementation Checklist
Use this implementation checklist to achieve compliance with ISO 27001 Annex A 5.1 Policies for Information Security. This guide focuses on integrating compliance into your existing workflows, avoiding the “checkbox fatigue” often caused by isolated GRC dashboards.
1. Define Policy Structure
Control Requirement: Information security policy and topic-specific policies shall be defined.
Required Implementation Step: A “Policy Master List” or index document that categorizes your top-level “Statement of Intent” (signed by the CEO) separately from operational rules (like Access Control or Clear Desk).
Minimum Requirement: A simple spreadsheet listing the 15-20 policies you intend to enforce, mapped to the risks they mitigate.
2. Draft Topic-Specific Policies
Control Requirement: Topic-specific policies must be defined to address specific risks.
Required Implementation Step: Clean, readable PDF documents generated from Word or Google Docs that outline specific “Do’s and Don’ts” for staff (e.g., Acceptable Use Policy, Remote Work Policy).
Minimum Requirement: Written rules that are specific to your technology stack (e.g., “Use 2FA on Google Workspace”), not generic boilerplate text.
3. Embed Document Control
Control Requirement: Policies must be reviewed and maintained.
Required Implementation Step: A visible header table on the first page of every policy containing: Version Number, Author, Approver, Effective Date, and Classification (e.g., Internal).
Minimum Requirement: Ensure the file name matches the Title inside the document and includes a version number (e.g., Access_Control_Policy_v1.0.pdf).
4. Secure Management Approval
Control Requirement: Policies must be approved by management.
Required Implementation Step: An email thread or Steering Committee meeting minutes where the Leadership Team explicitly agrees to the content of the policies.
Minimum Requirement: A saved email from a C-Level executive stating, “I approve these policies for publication.”
5. Publish to Intranet
Control Requirement: Policies must be published.
Required Implementation Step: A dedicated “Security Centre” page on your existing Company Intranet (SharePoint, Confluence, Notion) where all current PDFs are hosted.
Minimum Requirement: A shared, read-only folder link accessible to every employee without requiring a special login.
6. Broadcast Communication
Control Requirement: Policies must be communicated to relevant personnel.
Required Implementation Step: A multi-channel announcement (Slack/Teams channel post + All-Hands Email) linking to the location of the new policies.
Minimum Requirement: Evidence of an email sent to the “All Staff” distribution list announcing the release.
7. Capture User Acknowledgement
Control Requirement: Policies must be acknowledged by relevant personnel.
Required Implementation Step: A Microsoft Form or Google Form linked in the communication email that captures the employee’s name, date, and agreement statement.
Minimum Requirement: A timestamped spreadsheet export showing who accepted the policy and when.
8. Schedule Annual Reviews
Control Requirement: Policies must be reviewed at planned intervals.
Required Implementation Step: A recurring calendar series in the Policy Owner’s calendar (e.g., every 12 months) dedicated to reviewing the documents.
Minimum Requirement: A screenshot of the calendar invite for the next review cycle.
9. Establish Change Triggers
Control Requirement: Policies must be reviewed if significant changes occur.
Required Implementation Step: A line item in your Change Management Policy stating that “Major Infrastructure Changes” trigger an immediate review of relevant security policies.
Minimum Requirement: Evidence that a policy was updated (version incremented) following a major tool swap (e.g., moving from On-Prem to Cloud).
10. Archive Obsolete Versions
Control Requirement: Prevent unintended use of obsolete information (implied by document control standards).
Required Implementation Step: A restricted “Archive” folder where old versions (e.g., v1.0) are moved immediately upon the release of v1.1.
Minimum Requirement: Separation of “Current” and “Retired” policies so staff cannot accidentally access old rules.
ISO 27001 Annex A 5.1 SaaS / GRC Platform Implementation Failure Checklist
| Control Requirement | The “Checkbox Compliance” Trap | The Reality Check |
|---|---|---|
| Management Approval | A “Click to Approve” button in a dashboard that leaves no external audit trail and is often clicked by a delegate, not the CEO. | Auditors require evidence of actual leadership engagement, such as meeting minutes where the policy implications were discussed. |
| Staff Acknowledgement | Users selecting “Accept All” on a list of 20 policies they haven’t opened, clearing the dashboard notification in seconds. | A quiz or form that forces the user to interact with the content (e.g., “What is the minimum password length?”) to prove understanding. |
| Availability & Access | Policies locked behind a GRC tool login that 90% of staff never access or have forgotten their password for. | Policies hosted on the Company Intranet or Shared Drive where staff perform their daily work. |
| Document Control | The tool automatically updates the “Last Reviewed” date without a human actually reading the content. | A manual version history log inside the document detailing exactly what changed (e.g., “Added section on AI usage”). |
| Communication | Automated “No-Reply” emails from the platform that get filtered into employees’ Spam or “Updates” folders. | A genuine internal marketing campaign (Slack, Town Halls) ensuring the team knows why the policy matters. |
| Relevance | Using the “Standard Policy Pack” provided by the SaaS vendor without removing references to mainframes or fax machines. | Policies edited to reflect the specific tools, locations, and workflows actually used by the organization. |
| Review Cycle | Closing a recurring ticket in the system to “turn it green” without opening the policy document. | Calendar evidence showing time was blocked out and used to critically assess the policy against current risks. |
About the author
